# A.DELTA~~

November 5, 2012
Docket Operations, M-30 KirkThornburg Managing Director
- Aviation Safety & Assurance Corporate Safety, Security, & Compliance

U.S. DepartmentofTransportation (DOT) 1200 New Jersey Avenue, SE Room W12-140, West Building Ground Floor Washington, DC 20590-0001 Re: Docket Number FAA-2012-21826 Comments Dear Sir: Delta Air Lines, Inc. 1020 Delta Blvd Department 041 Atlanta, Georgia 30320 404-773-9913 Kirk.Thornburg@delta.com



### ...,.;.

Delta Air Lines submitted information on October 30, 2012 against Docket FAA-2012-0752 that may be useful to the FAA in its rulemaking interest regarding the use ofcell phones in flight. In the attached letter, Delta provides information from a survey of 1462 customers on their preferences for expanded use ofcell phones in flight and outlines a Safety Management System (SMS) approach to address potential interference with aircraft systems. Delta Air Lines supports expanded use ofcell phones and PEDs in flight but takes a position thatvoice cellular calls should be limited to ground operation only. Sincerely, 

# l&1c<; 

# J
KirkThornburg Managing Director, Aviation SafetyAssurance
Attachment: Delta submittal to Document FAA-2012-0752

# ~.DELTA~-~

October 30, 2012 Docket Operations, M-30 KirkThornburg Managing Director- Aviation Safety &Assurance Corporate Safety, Security, & Compliance

U.S. Department 

### ofTransportation (DOT) 1200 New Jersey Avenue SE, Room W12-140 West Building Ground Floor Washington, DC 20590-0001 Re: Docket number FAA-2012-0752 Comments Dear Sir: DeltaAir Lines, I,nc. 1020 Delta Blvd Department041 Atlanta, Georgia 30320 404-773-9913 Kirk.Thornburg@delta.com

Delta Air Lines is supportive ofthe FAA's review ofcurrent policy regarding the use 

### of Portable Electronic Devices (PED) on aircraft. PEDs are nowwidely accepted into our society and are integral devices to mostAmerican's daily lives. Itshould be thejoint responsibility ofthe aviation industry and the FAA to plan future airtravel such that aircraft operating systems are compatible with PED operation. An Aviation Rulemaking Committee (ARC) comprised oftechnical and operational experts in the aviation community, technical and operational experts in the PED community, the FAA, and the FCC can be an effective vehicle to accomplish this objective. Delta believes that strictoversight ofthe ARC with specific deliverables and completion timelines is essential forthe effort to be successful. As technology has developed in the last 30 years, the industry has worked similarlywith the FAA to develop acceptable system standards and operational guidelines for In Seat Power Systems, Wireless InternetSystems (Wi-Fi), and manyon board server based Passenger Entertainment Systems. Airline travel mustadapt to the needs ofthetraveling public, but it mustdo so with a plan that ensures critical aircraft systems will not be affected by these devices

.. Delta Customer Input In support ofthe FAA's efforts via this docket, Delta recently surveyed 1462customers over the issue ofexpanded PED usage on flights. Ourcustomers responded as follows:

o When asked to pick which device theywould like to use the most below 10,000feet, cell phone is the top choice followed closely by tablet computer. o Reading e-books, text messaging, listening to music, watching movies and playing games are the top activities that customers would like to do below 10,000feet Note: Ofthe activities available on today's smartphones, making cellularcalls is only the 6t11 priority o Most customers feel that being able tp use electronic devices below 10,000feet would have a positive impacton the onboard experience o The abilityto make phone calls is seen to have a negative impacton the onboard experience for 64% ofcustomers; however, 36% ofcustomers believe itwould be positive indicating that phone calls in flight can be polarizing.Impacton Onboard Experience is allowedtouse PED's Below 10,000 Feet

100%

### l 80%1 60%-; ' 40%-; 20% l

0% -20%-: I -40%

# 1 -60%] -80%

# J ·100%

Delta OoerationsView • Very Positive
• SomewhatPositive
• SomewhatNegative
• Very Negative

An importantobjective ofexpanded PED usage should include assurance thatthe safety function dutiesassigned to our Flight Attendants are not diminished due to an additional requirementto police on board PED usage to a greaterdegreethan today. In the last 12 months, data available to Delta from our in flight reporting systems show an increase in passenger non compliance to current PED usage policy with no corresponding increase in safety events. Ourdata shows the following:

o 99% ofpassenger PED non compliance occurs in the taxi out portion ofthe flight o 95% ofpassenger PED non compliance were related to cell phone usage o No increase in actual operational safety events The ARC Is urged to recommend rulemaking thatassures thatflight attendants continue to devote theirtimeto in-flightsafety assurance functions and thatthe industry finds other means to satisfy compliance with expanded PED operation on aircraft. As opposed to an effortto require flight attendants to ask passengersto puttheir PED down for important safety briefing announcements, benchmarking ofother industries should be examined to determine ifthere is a betterway to ensure safety briefings are communicated to all. Ifnot addressed, too much ofourflight attendantstime is focused on PED operational compliance ofcabin readiness and not balanced across the greater need to assure thatthe cabin is properly prepared for each phase offlight. Itshould be the objective oftheARC to confirm PED usage is safe within today's Safety Management Systems Risk Acceptance guidelines. Once PED operation is confirmed safe for all phases offlight, flight attendantdutiesfor PED usage should be similarto monitoring passenger's usage ofa book or newspaper. ' Safetv Management System (SMS) Data Availability Delta has implemented a Safety Management System which allows identified hazards to our operation to be collected across a numberofsafety reporting systems. To respond tothe agency's request to comment on the current PED usage policy, Delta canvassed our 2Maintenance defect reports and PilotAviation Safety Action Program (ASAP) reports. Since January 1, 2010 at Delta Air Lines, representing 2.3 Million flights, Delta pilots mentioned PED as a potential source ofan observed flight equipment discrepancyon only 3 occasions. A review ofmaintenance defect reports during the same time period revealed 24 reports where Delta mechanics mentioned the possibility ofPED interferencewhen resolving avionics system irregularities. However, in each ofthe 24 mechanical defect reports, Delta was notable to confirm a PED was the cause ofthe anomaly, only thatour mechanics felt that Itwas a possibility forthe defect. When combined, 27 pilot and maintenance reports outof2.3 million departures during this period thatsuggested the possibility ofPED interference existat Delta but none were able to be confirmed by any operational or maintenance methodology. Use ofSafety Management System (SMSl Principles The FAA has regulation pending requiring US airlines to implementa safety management system to identify hazards and implement mitigation to operate aircraft atan acceptable risk level. As a partofthis effort, SMS assessmenttools are now available which define risk across a matrix oflikelihood versus severity. Each carrier either has, orwill be, adopting a system that meets the pending rule. Each carrierwill demonstrate its assessmenttools are in place to its FAA Flight Standards oversightorganization. Delta believes that advances in technology both in the PED and aircraft system designs have reduced the likelihood ofan Interference condition occurring in all phases offlightto a level thatcan be accepted with mitigation. The July 2012 FAA study on the use ofcell phones on passenger aircraft cites information from several International civil aviation authorities that have approved installation ofonboard cellular telephone base stations that cell phones and base stations have not interfered with aircraft systems. Anecdotally, Delta passengers and crew will confirm thaton numerous flights some number ofpassengers inadvertently leave their PED on and as reported above, we have only three flights where a Delta flightcrew thought a PED could possibly have caused interference. In theJuly 2012 FAA study, the French**D~AC** noted that approximately 10 percent ofcell phone users forgottoturn their cell phone offeven when the onboard cellular base station was notoperating. Traditionally, airlines have used on board testing to confirm in-flightWi-Fi systems and ground usage ofcell phones have not interfered with aircraft systems. However, continued reliance on testing ofevery PED against every potential aircraft system Is an untenable task. The industry must look to other methods to identify hazards and mitigate risk. Delta encourages the ARC to look tothe SMS methodologyforalternative means to demonstrate acceptable expanded use of PED in flight. An acceptable SMS model may include: 1. Acceptance orvalidation ofthe anecdotal data available thatsuggests aircraft have flown forthe last 15 years with a variety of PED with an extremely remote likelihood ofinterference occurring. 2. A mitigation strategy that examines existing pilotabnormal procedures for inaccurate/inop avionics equipmentand determines ifan additional procedure for PED interference may be warranted for one or more systems 3. Asafety assurance function that continuously examines mechanic and flight crew reports where PED interference is mentioned. Also ofnote are Boeing studies reported in a March, 2000 Boeing commercial publication where Boeing purchased PED from passengers thatwere confirmed to have caused interference on 737 and 767 aircraft. Boeing tried to recreate the interferencewith the PED with subsequenttesting ofthe known devices on otheraircraft but could not duplicate 

### 3the anomaly. Boeing concluded "As a result ofthese and other investigations, Boeing has not been able to find a definite correlation between PEDs and the associated reported airplane anomalies." Delta urges the FAA to have the ARC assess the role of interference testing in expanding the use of PEDs on aircraft. In addition to the complexity involved in testing combinations of PEDs againstthe many aircraft systems in service, the reliability ofonboard testing to actually detect a potential anomaly appears remote. Forthese reasons, Delta promotes a risked base SMS assessment as a stronger methodology to safely expand the use of PED on aircraft. As is standard in our industry, Delta Flight Crews are trained to handle system interruptions and inaccurate display information today. An assessment ofthese non normal instructions againstthose interruptions and inaccurate displays that could be caused by PED interference should be accomplished. Where additional orsupplemental procedures are called for, airlines should enhance their non normal instructions and training. Ifthe industry comes to the conclusion that interference must be addressed, Delta suggests the focus center around the need to protect airtravel against intentional electrical signal jamming devices. Delta is encouraged by Network Control Unit (NCU) devices available in the markettoday that prevent onboard CMRS Mobile Stations (MS) from transmitting and therefore registering with terrestrial base stations. These NCU devices prevent mobile stations from transmitting by masking all possible cellular channels with an RF signal powerful enough to overcome possible signals received in the cabin from terrestrial base stations. Our Operations area suggests that the threat ofan onboard intentionaljamming device be assessed in this effortsuch that harmful RF signals generated from on board the aircraft are prevented from interfering with ships equipment as well. We believe the technology exists todayto achieve this and should be examined and weighed as one possible mitigation strategy that could be made available to an operator. Examine Other Industries The expanded use of PEDs in today's society is a question not reserved forthe commercial airline industry. We believe that many industries have examined this issue and could offer similar risk based approaches thatwe suggest above oralternate strategies to be considered. Delta notes relaxed cell phone policies in local hospitals are in place today. Interference between PED and medical devices (pacemakers, image/scan equipment, etc) draw a good comparison forthe on board aircraft environment and we recommend that the ARC examine othersafety sensitive industries for approaches to PED operation in theirfacilities. Technical Recommendations Delta believes thattechnical challenges are solvable in and regulatory changes are the key element in expanding PED use on the aircraft. That said, the ARC should address the following areas as part ofa long term strategy to ensure compatible operation of PED and aircraft avionics systems:

o Delta supports adoption ofstandards for PED and aircraft system designs Examine harmonizing PED FCC part 15 emission limits with D0-160 part 21 Cat M standards. Develop a database similarto the PMA process, to access data on all PED's that have passed D0-160 part 21 Cat Memissions tests Recommend the ARC assess all new aircraft designs to be PED tolerant 4- Assess new installations on existing aircraft to be PED tolerant.

- Assess thatTC or STC applicants demonstratethat PED operation is not compromised by the submitted design changes.

- Define "Airplane mode'' as used to describe device operation and attain agreement between aviation and PED Industries as to thatdefinition.

o Delta supports clarity of PED article retention risks

- Seek a definition ofprojectiles, which do not require stowage during takeoffand landing (such as a book), in terms ofcurrent PED form factors.

- Certification of literature pockets should be evaluated to allow carriers to approve larger PEDs (up to and including laptops for example) to remain stowed in literature pockets during takeoffand landing operations.
o Delta supports efforts to find effective deterrentsfor Intentional harmful interference detection. Key elements ofthis area should include

- Application oftechnology to block on board as well as terrestrial based signal acquisition on aircraftsuch as the Network Control Unit (NCU) devices.
o Delta supports a specific effortto broaden the scope of 14 CFR 382 which requires medical respiratory devices to meet FAA electromagnetic and radio frequency emission standards. Key factors to consider:

- Inclusion ofothercritical medical devices being brought on board aircraft today. Delta recommends that the DOT or FAA provide recommended labeling ofdevices meeting FAA electromagneticand radio emission standards.

- Many medical devices only meet medical IEC/EN specification orother nonaircraft level test standards so are not allowed during taxi, takeoff, and landing.

- Devices may meet FAA/IEC/EN specifications and still not be recommended for use in aircraftdue to lack ofbattery oraccuracy ofdevice on aircraft. Delta Position and Recommendations After review of PED usage With ourcustomers and Delta Operations personnel, Delta comes to the conclusion that it is time that portable electronic devices are fully integrated into air travel. Technology in use on aircraftand in the PED industry has advanced such that interference events are extremely rare. The benefits ofexpanded in-flight PED usage outweigh the extreme low risk ofan actual interference event occurring based on the data Delta has assembled. Delta supports the formation ofan Aviation Rulemaking Committee to expand the use of PED during all phases offlight operations. We see the following objectives in such an effort: 

### 1. Expand the use ofcellular telephone communication (voice calls) to all phases 

### of ground operation. as determined practical by each airline operator. Most of Delta's passengers (64%) have told us thatthe ability to make phone calls in flightwould have a negative impacton the onboard experience.



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### 2. Use SMS Risk Based Methodology to ensure safe PED operation. This approach should replace the untenable task oftesting every PED against all aircrafttype designs and type design variants. 3. Expand the use ofall non voice/non sound PED during all phases 

### offlight. Continue to allow the aircarriers to make the determination what PED are authorized in flight. Encourage the Industryto develop standards that PED will be qualified against in the future. When these standards are available, the burden ofauthorization ofdevices can be removed from the aircarrier. Furtherwe desire the commercial environment ofonboard equipment manufacturersto stay competitive. These systems should only be required to meetstandards determined by the FAA for non interference to aircraft avionics systems. We urge the FAA to allow airlines to choose from a broad selection ofonboard entertainment and communication systems and products in the future. Delta appreciates the opportunityto comment on thisFAA initiative. In addition to providing a position ofsupport to the agency through this letter, Delta will dedicate personnel, technical information, and in flightdata to help the ARC effort move forward. Should you have any questions on our comments, please contact KirkThornburg, Managing Director, Aviation SafetyAssurance at404-433-6903 or kirk.thornburg@delta.com. Sincerely,

# ~0:~fhs Managing Director, Aviation SafetyAssurance

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